Seven Things CEOs Boards Should Ask About Climate Reporting

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    Climate change and sustainability

    Seven questions CEOs andboards should ask about‘triple bottom line’ reporting

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    1. Who issues sustainability reports?

    03More than 3,000 companies worldwide, including more than two-thirds of the Fortune Global 500.2. Why report on sustainability if you don’t have to? 07

    Increasingly, external stakeholders such as institutional investors expect it. Reporting can alsobring operational improvements, strengthen compliance, and enhance your corporate reputation.

    3. What information should a sustainability report contain? 11Reports should contain key performance indicators relevant to the reporter’s industry.Four principles for deciding what to include are materiality, stakeholder inclusiveness,sustainability context, and completeness.

    4. What governance, systems and processes are 15needed to report on sustainability?Governance requires a high-level mandate and clear reporting lines. Also needed: robust systemsand processes that help companies collect, store and analyze sustainability information.

    5. Do sustainability reports have to be audited? 19Not yet. But they are being more closely monitored than ever before. As this trend continues,users of sustainability information will come to expect that the information has beenvalidated by a reliable third party.

    6. What are the challenges and risks of reporting? 23Sustainability reporting presents many challenges, including data consistency,striking a balance between positive and negative information, continually improvingperformance and keeping reports readable and concise.

    7. How can companies get the most value out of 27sustainability reporting?Sustainability reports should be mandatory reading for all employees, and can be a valuabletool for communicating with external audiences as well. Setting targets in the form of KPIs alsoforces the organization to meet publicly stated goals, which makes reporting an accountability tool.

    Contacts 30

    Contents

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    In the face of mounting pressure to be transparent, a growing number of organizations are choosing

    to report on sustainability or corporate social responsibility (CSR). Sustainability reports help readers

    understand how well the reporting organization adheres to the “triple bottom line” of environmental, social

    sustainability-related risks and opportunities facing the reporting entity, whether it’s a public or private

    An organization that reports on its sustainability practices is expected to show not only where it has

    succeeded, but where it may have fallen short. This creates an element of reputational risk in the short

    organization’s “triple bottom line” performance; greater stakeholder trust; improved risk management; and

    data on issues such as greenhouse gas emissions (GHG), water use, and supply chain activities can help

    companies enhance decision-making while reducing risk.

    Failure to report on sustainability, by contrast, can increase risk. Companies that do not release

    sustainability information may appear less transparent than competitors that do, coming across as laggards

    becomes mandatory and standards are tightened, glaring discrepancies might appear between past reports

    and newer ones. All of these factors have created momentum in the direction of more openness and

    more reporting.

    Although most reporting is voluntary, the broad trend is toward greater disclosure. Voluntary reporting

    standards have been developed to guide organizations in preparing sustainability reports (see Section 3).

    As a result, many are considering reporting, but have not yet set up the processes and systems needed

    reputation and to reduce any long-term risks related to sustainability.

    boards should ask about‘triple bottom line’ reporting

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    Reporting is sometimes thought of as the

    province of large organizations, but it’sbecoming common among midsize andsmaller enterprises as well.

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    questions they ask is, “Who else is doing this?” More than 3,000 companies worldwide

    Ford, Johnson & Johnson, Chevron, ConocoPhillips, Xerox, Microsoft, Cisco, HP, Disney,

    Procter & Gamble and Best Buy. Among European companies, reporters include Vodafone,

    Siemens, Shell, BASF, ArcelorMittal, Novartis, Carrefour, Nokia, HSBC and Novo Nordisk.

    Sustainability reporting was originally done mostly by consumer-based businesses and

    Permanente, cities including New York and Chicago, and even business and trade associations.

    Reporting has developed more slowly in North America than in some other regions.

    nearly 20 years ago. In Sweden, all state-owned companies are required to report publicly

    on sustainability. Japanese companies predominate in sustainability reporting in Asia, but

    Chinese companies are starting to do it as well.

    Reporting is sometimes thought of as the province of large organizations, and many reporting

    entities are indeed big multinationals. But the practice is also becoming common among

    midsize and smaller enterprises. For example, Vancouver City Savings (Vancity), a midsize

    credit union, based in Vancouver, Canada, is a leading sustainability reporter.

    1. Who issuessustainabilityreports?

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    Research by Ernst & Young shows that more than two-thirds of the Fortune Global 500

    companies publish some form of sustainability or corporate responsibility report.

    with a long-term trend.

    Although reporting is voluntary,the broad trend is toward greaterdisclosure.

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    Companies that have adopted leadingpractices in sustainability reportingBHP Billiton

    stakeholders to clearly understand the issues BHP Billiton faces and the management strategies in place to address them.www.bhpbilliton.com/bb/sustainableDevelopment.jsp

    Veolia Environnement

    information into their annual report and accounts. Leading reporters integrate them fully, rather than just including a small

    www.sustainable-development.veolia.com

    Vancouver City Savings (Vancity)

    Sustainability Reporting Award. Vancity was praised for clearly demonstrating how it engages stakeholders and forintegrating “triple bottom line” thinking into its business operations.www.vancity.com/AboutUs/OurBusiness/OurReports

    Telefónica S.A. This major Spanish telecommunications company is recognized for adding credibility to its reporting through third-partyassurance. It was a runner-up in the CR Reporting Awards conferred by Corporate Register, an organization that promotescorporate responsibility worldwide. publications.telefonica.com/node/46131

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    Equity analysts increasingly consider

    sustainability practices when valuing andrating public companies.

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    Pressure from external stakeholders

    Although most reporting is voluntary, companies face growing pressure to release information

    community associations, customers, suppliers and employees want more information

    about companies’ long-term impact on society. In particular, powerful customers can force

    companies to become more transparent, the classic example being Walmart, which launched a

    supplier sustainability initiative in July 2009.

    Pressure from institutional investors

    Shareholder initiatives such as the United Nations Principles for Responsible Investment

    its kind, Principles for Responsible Investment is one of the largest: its 800 signatories

    manage more than US$22 trillion in capital and include large investment funds such as

    BlackRock and TIAA-CREF. There has even been a proliferation of indices benchmarking

    the stocks of companies seen as sustainability leaders. These include the Dow Jones

    Global Sustainability 50 Index.

    In addition, sustainability data is now available to institutional investors through commercial

    information services such as Bloomberg and Thomson Reuters, and to individual investors

    through websites such as Fidelity.com. Stakeholders can easily obtain a company’s

    2. Why reporton sustainabilityif you don’thave to?

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    sustainability information and compare its reports with those of its competitors. More than

    information such as emissions data, energy consumption, human rights information,

    corporate policies and board composition. Thomson Reuters gives more than 400,000

    subscribers access to similar information at the touch of a button. Institutional investors

    and other users are reviewing sustainability data over time, comparing it across and within

    industry sectors, and sometimes ranking disclosure levels and reporting quality. Such

    scrutiny makes it important that companies maintain complete and accurate data on their

    sustainability practices.

    Research also indicates that equity analysts increasingly consider sustainability practices

    when valuing and rating public companies. In mid-2010, a global Ernst & Young survey of

    300 executives at large companies showed that 43% believe equity analysts consider factors

    related to climate change when valuing a company. More recently, a study by Ioannis Ioannou

    of the London Business School and George Serafeim at Harvard showed that equity analysts

    have begun giving higher ratings to companies with exemplary CSR practices. The research,

    published in August 2010, surveyed more than 4,100 publicly traded companies over a

    16-year period. It found that since 1997, analysts have viewed CSR strategies as creating

    in recent years they have issued more favorable ratings to companies that have sustainability

    strategies in place.

    Operational improvements

    reporting helps companies identify sustainability-related opportunities for revenue growth and

    cost containment. Although it may be a truism to observe that “what gets measured gets

    Sustainability reporting helps companiesidentify opportunities for revenue growthand cost containment.

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    managed,” reporting requires measurement, and this in turn helps companies manage their

    In February 2010, the Securities and Exchange Commission (SEC) published interpretive

    guidance regarding its disclosure requirements related to climate change risk. Issued in

    response to petitions from several institutional investors, the guidance does not amend

    any existing disclosure requirements or create any new ones; however, it does signal that

    companies should maintain a heightened awareness of climate change risk when preparing

    maintaining such awareness.

    Regular reporting could also prevent companies from running afoul of stricter “truth in

    on companies to substantiate claims such as statements that products are “recyclable” or

    “carbon neutral.” Product claims made in a sustainability report could be subject to this new

    guidance. Reporting on “green product development” gives organizations an opportunity to

    document the basis for any such claims they make.

    Reputation management

    Done properly, reporting on sustainability helps companies establish a reputation for

    transparency and build stakeholder trust. Research conducted by the Global Reporting

    Initiative (see next section) shows that 82% of US companies and 66% of those in Europe cite

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    By reporting on sustainability,organizations can show stakeholdersthat they have been heard.

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    Although no universal reporting standards exist yet, there are some widely used voluntary

    guidelines that prescribe the kind of information companies should disclose. Together, these

    widespread use, including the AA1000 AccountAbility Principles Standard and the Global

    Reporting Initiative (GRI) Reporting Framework.

    The GRI guidelines have been updated twice since their inception, making the current version

    the “third generation” or G3. Developed in consultation with private industry, it is currently

    used in 65 countries and comprises a set of core guidelines that apply to all organizations,

    plus supplemental guidance applicable to particular industries. GRI also has issued protocols

    human rights.1

    GRI suggests some guidelines for ensuring that reports are of acceptable quality. They should

    be timely, for example, and clearly understandable to nonexperts. They should be balanced,

    And they should be accurate, meaning that certain types of oversight or assurance are necessary.

    1 Several components of the GRI Guidelines are undergoing revision, including community impact, human rights,gender and report content and materiality. A 90-day public comment period ended in August 2010. Version G3.1 ofthe Guidelines is expected in early 2011.

    3. Whatinformationshould asustainabilityreport contain?

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    Most organizations develop key performance indicators (KPIs) on which to report. Some set

    targets for limiting their total direct and indirect greenhouse gas emissions by weight; others

    measure the percentage of recycled materials used in their business, or the size and

    biodiversity value of the water bodies affected by their operations. A 2010 report by Harvard

    develop KPIs that take into account the types of indicators typically associated with the

    reporter’s industry peers.

    Choosing the issues and indicators to focus on, and determining the reporting boundaries,

    are fundamental to the preparation and quality of any report. To make those choices, an

    with its activities. Stakeholder engagement is one means of identifying issues that are

    material to society, and therefore to an organization. Leading reporters use what they learn

    from stakeholder engagement to formulate strategies and operations that are consistent

    with sustainable development. By reporting on sustainability, organizations can respond to

    stakeholder concerns and expectations, showing stakeholders that they have been heard.

    GRI suggests that organizations use four main principles for identifying material issues to

    disclose in their reports (See box to the right).

    Most organizations develop keyperformance indicators (KPIs)on which to report.

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    Deciding what to disclose: guidelines from GRIMany companies follow the GRI framework when deciding what to include in their sustainability reports. The framework startswith a series of principles that organizations can use to judge whether a particular piece of information merits inclusion intheir sustainability reports. The principles are materiality, stakeholder inclusiveness, sustainability context, and completeness.

    Materiality —

    extend to factors with longer-term implications. Determining what is material requires that the organization assess its“overall mission and competitive strategy, concerns expressed by stakeholders, broader social expectations, and the

    Stakeholder inclusiveness — Reports should respond to stakeholders’ “reasonable expectations and interests.” In this

    or whose actions are likely to affect the organization’s ability to carry out its business strategy and achieve its goals.

    Sustainability context — The purpose of a sustainability report is to show how an organization is helping to improve (orat least halt the deterioration of) environmental, social and other conditions over the long term. Reporting on isolated or

    income levels and the capacity of social safety nets to absorb those in poverty or those living close to the poverty line.”

    Completeness — performance in the reporting period.

    Source: GRI Sustainability Reporting Guidelines, Version 3.0

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    Companies should begin moving beyondspreadsheet-based processes forgathering and reporting data.

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    mechanisms for doing so accurately and completely. This can be a challenge, because

    CSR information comes from a variety of business functions and geographic locations

    (see graphic on page 17).

    middle managers, sustainability reporting is a mandate that needs high-level support.

    A corporate governance structure with clear reporting lines helps establish the requisite

    backing from senior leadership and provides accountability at the operational level.

    Some organizations link sustainability performance to executive compensation, a step

    likely to sharpen organizational focus on the issue.

    4. Whatgovernance,systems andprocesses areneeded toreport on

    sustainability?

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    After governance mechanisms are in place, companies must consider how they will collect,

    store and analyze sustainability information. A need for more robust systems and processes

    will become increasingly evident as reporting requirements and regulations evolve,

    particularly those related to GHG emissions. The main principle to keep in mind is that

    processes grow more accurate as they become more automated because automation lowers

    the likelihood of manual error. To establish robust systems that meet their emerging needs,

    companies should begin moving beyond spreadsheet-based processes for gathering and

    reporting data. Larger companies are beginning to adopt web-based technologies, which can

    streamline reporting and lower its costs.

    Sustainability reporting is a mandatethat needs high-level support.

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    Controls needed for sustainability accounting

    reports, which are likely to become more common in the future.

    should evaluate the key role that application controls can play in sustainability reporting.

    Factors to consider include:

    Usability and functionality: Does the application function as designed?

    Access rights and controls: Does the system prevent unauthorized alteration ofdata by means of user authentication controls and access control mechanisms?

    sustainability information is accurate, valid, complete and timely? Does the system

    to prepare reports in accordance with the organization’s sustainability accounting policies?

    organizational needs? Can the same information be reported in different ways to supportvarious reporting purposes? Does the system export data for use in other applications?

    software vendor? What is the expected life span of the software?

    At this stage in the development of sustainability reporting software, no single application will meet all needs and objectives.Nevertheless, by considering their needs and the various software options available, organizations can move beyondspreadsheet reporting to automate systems and processes in a way that helps reduce error and makes reporting more accurate.

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    Users of sustainability information willcome to expect that the information hasbeen validated by a reliable third party.

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    North America currently has comparatively few requirements for third-party assurance of

    sustainability reports. Companies that emit a certain level of greenhouse gases are subject

    to reporting requirements, as are those in mining or other extractive industries, but they

    are exceptions to the rule. As sustainability reporting matures, however, stakeholder

    expectations are likely to rise, making external assurance a virtual requirement. Companies

    now obtaining a lower level of assurance, typically described as “limited” or “review”

    assurance, will come under pressure to move toward a “reasonable” or “examination”

    companies using its guidelines declare a reporting level of A,B or C, depending on how the

    GRI indicators are applied, then allows companies to apply a “plus” (+) at each level if they

    media read them to assess the sustainability performance of the reporting entities, while

    investment fund. As this trend continues, users of sustainability information will come to

    expect that the information has been validated by a reliable third party.

    Companies will begin seeking third-party assurance of their reports not only because of

    improving transparency, third-party assurance shows that the organization is serious about

    addressing the issues tied to its social, environmental and economic performance. It helps

    mitigate the reputational risk of reporting, especially that of having to restate performance

    information because of inaccurate data. Assurance sends a message that the report is

    relevant, reliable and free from bias. And third-party providers can sometimes recommend

    5. Do sustainabilityreports have tobe audited?

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    organization overall. In addition, some executives who sign the reports may desire third-party

    assurance to protect their personal reputations.

    Because rating agencies may use sustainability related information to assign a grade to the

    company’s debt, accurate sustainability reporting can help to lower a company’s cost of

    borrowing. Third-party assurance makes it more likely that ratings are based on accurate

    information. Having reports audited also helps to verify data used to set reduction goals.

    If a company sets a goal but does not reach it, this can be viewed as a failure. Much of the

    entity audit a report helps organizations assess whether their performance goals arebeing measured properly.

    Companies must take care when selecting an assurance provider. Global companies, or those

    with a combination of voluntary and mandatory reporting requirements, will need a provider

    Assurance sends a message thatthe report is relevant, reliable andfree from bias.

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    Standards for assurance in sustainability reportingThere are two primary global assurance standards. The International Standard on Assurance Engagements 3000(ISAE 3000) is the benchmark that accountants most often use as a basis for assurance of sustainability reports.It was developed by the International Auditing and Assurance Standards Board, whose standards exist primarily for

    assurance engagements.

    The other global standard, AA1000AS (2008), was designed for use beyond the accounting profession. It was created

    information, addresses management and reporting systems and processes. Using both ISAE 3000 and AA1000AS (2008)

    American Institute of CPAs’ AT101 and the Canadian Institute of Chartered Accountant Handbook Section CICA 5025,

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    By giving stakeholders somethingto measure, companies are putting

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    Although the rewards of reporting on sustainability can be great, there are challenges as well.

    Data consistency poses a risk, particularly if companies report through multiple channels such

    as printed reports, websites, and supplier sustainability indices. A major challenge consists

    of ensuring the comparability of data from different business units or subsidiaries and across

    reporting formats. A multinational corporation with operations in 10 countries, each using

    that do not allow for direct comparison.

    Intercompany comparability is another issue. Although data released by one company may not

    be comparable with that reported by others, stakeholders could mistakenly compare dissimilar

    data and draw erroneous conclusions. Even when some degree of comparability is achieved,

    organizations face the possibility that in reporting to a wide range of stakeholders, they may

    release inconsistent information through different channels. Many companies undertake

    benchmarking exercises to better understand the reporting practices of competitors,

    compare those practices with their own, and determine how stakeholders might perceive

    any discrepancies.

    Sustainability reporting also requires that companies strike the right balance of positive and

    negative information. Although reporting negative results could cause reputational damage,

    companies are expected to portray their sustainability practices “warts and all.” If reports

    closer inspection, don’t really exist. In all likelihood, companies that conscientiously apply one

    6. What arethe challengesand risks ofreporting?

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    of the various sustainability frameworks probably will not engage in greenwashing, simply

    reports mainly as a public relations tool are unlikely to fool anyone, since stakeholders who

    rely on sustainability information to make investment decisions are sophisticated enough to

    view excessively promotional claims with skepticism.

    The very process of reporting can create continual pressure on the company to improve its

    may expect to see constant improvement from one reporting period to another. By giving

    Another challenge: keeping reports readable and concise. Some companies place their

    sustainability data in a table or chart displaying KPIs in an easy-to-read matrix that tracks

    year-on-year progress toward the organization’s stated goals. This format is recommended by

    groups such as GRI.

    The very process of reporting can createpressure on the company continually toimprove its performance.

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    Smart companies use sustainability reportsto help reduce resistance, litigation andcreate a better public image.

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    Sustainability reports can be a valuable tool for communicating with both internal and external

    audiences. For starters, companies can use them to raise awareness inside the organization,

    making them mandatory reading for all employees. Reports also provide an excellent means

    of reaching a wide range of external stakeholders such as customers, suppliers, investors,

    Beyond their communications value, reports can help organizations accomplish goals related

    them to do. Setting targets in the form of KPIs, and communicating those targets externally,

    forces the organization to focus on meeting its publicly stated objectives. In this way, reporting

    becomes an accountability tool.

    In addition, companies in certain industries need to maintain their social license to operate.

    7. How cancompaniesget the mostvalue out ofsustainabilityreporting?

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    other expensive distractions quickly raise their cost of doing business. Smart companies use

    sustainability reports to ensure less resistance, less litigation and a better public image, all of

    Finally, as government entities and private-sector companies develop supplier sustainability

    new information when a potential customer requests it as part of the supplier vetting process.

    Next steps

    Where sustainability and the “triple bottom line” are concerned, the bar is rising. To meetit, companies must begin moving away from reporting designed mainly to generate positive

    publicity, and toward more rigorous and externally validated communications that address

    real business issues. Such a shift will require that management take a broader interest in the

    thought-provoking perspectives on capturing opportunities and reducing sustainability-related

    risk at ey.com/climatechange .

    Reports can help organizations cut costs,

    business imperatives.

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    A checklist of next stepsIf your company does not report on sustainability issues, or releases only a brief summary of its environmental impacts,here are some questions to consider:

    What feedback are we getting from our stakeholders?

    Is there pressure from our stakeholders to report?

    How are we perceived externally?

    Do we have a good understanding of the risks associated with sustainability?

    What are our peers and competitors doing?

    If your company currently issues a sustainability report, and wants to take its game to the next level, management shouldbe asking the following questions:

    Are we engaging and responding to our stakeholders?

    Do we want to be a leader in this area?

    What level of assurance do we currently obtain?

    Do we want a more rigorous process to ensure that our reporting is credible?

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    ContactsTo discuss how your organization can address these issues,please contact one of the individuals listed below:

    Ann BrockettAmericas Assurance Leader,Climate Change and Sustainability ServicesErnst & Young LLP+1 403 206 [email protected]

    Brian GilbertAmericas Climate Change andSustainability Reporting and Advisory ServicesErnst & Young LLP+1 312 879 [email protected]

    Steve StarbuckAmericas Leader,Climate Change and Sustainability ServicesErnst & Young LLP+1 704 331 [email protected]

    Melanie SteinerAmericas Climate Change and

    Ernst & Young

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    Five highly charged risk areasfor Internal Audit

    this means for Internal Audit.

    Action amid uncertaintyThis paper summarizes the results ofan independent, third-party survey of300 global executives on how theirorganizations are responding toclimate change risks and opportunities.